Carmaker’s Compliance with Federal Safety Regulations does not Bar Liability

Carmakers are not shielded from liability when they manufacture cars that comply with federal regulations, but are alleged to be defective under state tort law, the Supreme Court unanimously held on Feb. 23.

In Williamson v. Mazda Motor of America, the Supreme Court held that a California family can continue its lawsuit alleging that Mazda’s installation of a lap belt in the middle-rear seat in the 1993 Mazda MPV, even though the seat belt technically complied with the federal standard at the time it was manufactured. Our Annapolis Maryland Injury Attorneys have substantial experience aiding injuring people who have been injured by defective products.

The Williamson family argued in California State Court that the defective seatbelt system, which involved just a lap belt in the second-row middle sea, caused the death of their daughter Thanh Williamson.

Mazda argued that its seatbelt system complied with the federal standard when the vehicle was manufactured in 1993. The Federal Standard at the time gave automakers the choice of a lap belt or a lap and shoulder harness seatbelt in the middle rear-suit. Mazda argued that the Federal standard essentially gave Mazda a choice.

The California Courts agreed with Mazda, holding the doctrine of preemption applied. Under a doctrine called pre-emption, when a state law conflicts with a federal law, the federal law usually wins out.

The Supreme Court ultimately ruled that the state personal injury action was not barred by the doctrine of preemption because the “significant objective” of the federal regulation was not about giving manufacturers a choice of what kind of seat belt to install. The reason why the Department of Transportation (DOT) did not require three-point belts for all vehicles, according to Justice Breyer, was because at the time the DOT thought a requirement for lap and shoulder belts would not be cost effective.

The DOT, however, did not indicate an intent to bar legal action in state court, the Supreme Court held.

It should be noted that the Supreme Court did not rule on the underlying issue of whether Mazda created a defective seatbelt or if it was negligent. It does, however, mean that the Williamson family’s case can proceed.